We welcome much of the content of CP 9/20. It is clear both from
the proposals in the CP, and from the PRA’s timely and thorough
thematic work on the 20 fastest growing deposit takers, that all was
not well in the new bank and challenger sector, and corrective
prudential action was urgently needed. The PRA is to be commended
for making a start in this area. The main question is, not whether the
proposed SS is needed, but whether it goes far enough?
Our two general comments of principle are (i) that some of the
measures proposed for new and growing banks only, can and should
be made available - where appropriate -to established (non-systemic)
banks and building societies ; and (ii) to re-iterate that any new
building society should benefit from the same gradualist approach as
is applied to new banks.

Read the full response here.